Fulton v. Griffith

11 Ohio Law. Abs. 673, 1932 Ohio Misc. LEXIS 1175
CourtFayette County Court of Common Pleas
DecidedMay 19, 1932
DocketNo 17504
StatusPublished

This text of 11 Ohio Law. Abs. 673 (Fulton v. Griffith) is published on Counsel Stack Legal Research, covering Fayette County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fulton v. Griffith, 11 Ohio Law. Abs. 673, 1932 Ohio Misc. LEXIS 1175 (Ohio Super. Ct. 1932).

Opinion

RANKIN, J.

The question for determination is, Are the fees for services performed by the attorney for the administrator, in connection with the sale of real estate to pay debts of a decedent entitled to priority over a mortgage claim, where the mortgagee purchases the realty at judicial sale for a sum insufficient to discharge his mortgage claim?

Addams & Hosford in the new Ohio Probate Practice and Procedure at page 914 answer the above question in the affirmative. In the last edition of Deibel’s Ohio Probate Practice, Section 1118 and note, it is stated in effect that the new section does not make any change in the law on this question. In Volume 18 O Jur at page 750, §740, it is said that it would seem to be the rule under the new probate code that attorney fees would not be entitled to such preference.. ..

The solution of this question depends upon a construction of §10510-46 GC, which became effective January 1, 1932, the pertinent portion of which section provides:

“The money arising from the sale of real estate shall be applied as follows:
[674]*674“1. To discharge the costs and expenses of the sale, including reasonable fees for services performed by attorneys for the fiduciary in connection with the sale, and the commission of the executor or administrator thereon for his administration.
“2. To the payment of mortgages, judgments and tax liens” etc.

By comparing the above section with the former analagous §10809 GC we find that there has been no substantial change, except that the portion of the former section which we have underscored (printed in bold type) was not included in the old section.

The question as to the right of an executor or administrator to collect compensation under like circumstances was determined by the Supreme Court in an early case which has been repeatedly followed in this state. The case to which we refer is that of Stone v Strong, 42 Oh St 53, in which it was held that:

“If a mortgagee, whose lien is fixed by the court, becomes the purchaser at such sale, the executor or administrator is not entitled to a percentum compensation on that part of the purchase money applicable to the satisfaction of his mortgage.”

On page 57 of the opinion in the above case the court say:

“Can he charge a percentum on the amount of the purchase money going to a lienholder who is the purchaser?
“We think not. His percentum is to be computed on, ‘the money arising from the sale’, for, ‘his administration of the same.’
“Where no money arises, to be administered, there is nothing on which to compute commissions. This percentage was intended to compensate for the trouble and responsibility of collecting' and paying out the money. . . . Here the mortgagee is the purchaser, and so far as the purchase money is applicable to her liens, it operates as a satisfaction of her mortgages.”

We thus see that the Supreme Court has held that where a mortgagee becomes the purchaser of real estate atl a judicial sale for an amount less than his mortgage claim, the purchase money is directly applied to the mortgage lien and operates as a satisfaction of such mortgage. That case, therefore, expressly holds that under such facts there is no “money arising from the sale.”

The above case was followed by the Supreme Court in the case of Andrews, assignee v Johns, et al, 59 Oh. St 75. In that ease it was held that:

“The term ‘proceeds of real estate sold’, found in §6357, R. S., implies money arising from the sale actually received and accounted for as such by the assignee.”

On page 76 the court say that the term “money arising from the sale óf real estate”, is synonymous with the term, “proceeds of the real estate sold.”

On page 71 the Court say:

“The term ‘proceeds’ when used in connection with sale, . . means a sum of money derived from the sale of property. If money be derived from the sale, then it has yielded ‘proceeds,’ and an order distributing such ‘proceeds’ may follow; if none have been so derived then there are no funds in the hands of the court for distribution. . . But where no proceeds have been collected and accounted for, the proper order would seem to be one which would provide for such necessary costs as the statute authorizes, and satisfaction of the liens, and for a conveyance which will vest in the purchaser all the title of the assignor atl the time of the assignment, and thus close out the trust as regards that piece of property, and nob an order attempting to distribute that which is not within the control of the court. Now where the land exposed for sale by an assignee, which is incumbered by a mortgage constituting a first lien has been bid in by the mortgagee for a sum less than the amount owing on his mortgage, there can be no ‘proceeds’ in the sense of money for distribution, for the legal effect of the bid and sale, followed by confirmation and deed, is only to satisfy the mortgage, and the debt pro tanto, and vest in the mortgagee, purchaser, the equity of redemption of the assignor, and is nor to produce a fund for distribution. It has never been the law or practice in this state to require a mortgagee, purchasing under such circumstances, to pay the amount of his purchase either to the officer making the sale, nor into court. The reason is that having already the legal title subject to the equity of redemption of the mortgagor, the purchaser is in a sense the owner, and requires only a satisfaction in a legal manner of the equity of redemption, and of any subsequent liens, followed by possession, in order to give him a complete title .to the land.”

Sec 10510-46 GC provides that:

“The money arising from the sale of real estate shall be applied”, etc. But under [675]*675the state of facts which we are considering there was no “money arising from the sale and consequently nothing out of which the court was authorized to order payment of attorney fees. Where real estate is sold at judicial sale and the mortgagee bids in the premises for an amount less than his mortgage such sale amounts to nothing more than a satisfaction of the “mortgage, and the debt pro tanto” and extinguishment of the equity of redemption. Under such facts, as we have seen, the purchaser, mortgagee, is required to pay nothing because of his purchase, except such costs as ordinarily are incurred in foreclosure proceedings. In this case the conditions in each of the mortgages had been broken and the mortgagees were the legal owners of the real estate and the only interest which the decedent had therein was an equity of redemption. By the purchase .by the mortgagees they simply retained that which was airead theirs.

The costs which a mortgagee is required to pay, under such circumstances' are discussed in the case of Andrews, Assignee v Johns, et al, supra, at page 79:

“The court having found that the land was bid off by the owner of the first lien for a sum less than his debt, taxes and ■ costs, an order that the purchaser pay such taxes as were due, and such costs as might properly be required of him under the statute, which would be such costs, and such only, as were made necessary by the foreclosure, and upon such payment a deed be made by the assignee, would have met the situation as it existed and worked out the proper result.”

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Bluebook (online)
11 Ohio Law. Abs. 673, 1932 Ohio Misc. LEXIS 1175, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fulton-v-griffith-ohctcomplfayett-1932.